Between 1 July 2023 and 30 June 2024

1,449 complaints received

Life insurance complaints received

Top five life insurance complaints received by product

Product

2019-20

2020-21

2021-22

2022-23

2023-24

Income protection

530

575

650

523

540

Term life

331

290

359

347

310

Total and permanent disability (TPD)

179

184

227

210

224

Whole of life

59

115

231

231

117

Funeral plans

162

169

880

441

109

Top five life insurance complaints received by issue

Issue

2019-20

2020-21

2021-22

2022-23

2023-24

Delay in claim handling

155

172

204

245

231

Incorrect premiums

181

213

286

209

176

Denial of claim

270

212

171

145

165

Claim amount

131

95

112

141

111

Cancellation of policy

107

92

150

131

94

1,411 complaints closed
Average time to close a complaint: 121 days

Life insurance complaints closed

Average time to close a life insurance complaint in days¹

Stage at which life insurance complaints closed

Stage

2019-20

2020-21

2021-22

2022-23

2023-24

At registration

497

513

603

529

514

At case management

853

698

718

666

634

At rules review

151

104

186

125

109

Decision

209

280

383

148

154

Time taken to close life insurance complaints

Time

2019-20

2020-21

2021-22

2022-23

2023-24

Closed in 0-30 days

173

154

222

197

204

Closed in 31-60 days

405

361

444

405

397

Closed in 61-180 days

769

715

781

589

474

Closed in 181-365 days

328

289

347

223

262

Closed in more than 365 days

35

76

96

54

74


¹ This excludes complaints that were inactive for an extended period, for example, complaints that were paused because the financial firm was insolvent or due to court proceedings, and complaints that were previously closed and then re-opened.

Key complaint trends

Complaint closure rates show a modest decline

AFCA closed 1,411 life insurance complaints in 2023-24, marking a 4% decrease from the previous year.

Improvements in resolution time

 Notable progress was made in resolution times, with 14% of complaints resolved within 0-30 days. Additionally, 28% of complaints were settled within 31-60 days, and 34% were resolved in 61-180 days.

Extended resolution times increase

Complaints taking over 365 days to resolve increased by 37%. The rise in complaints taking over 365 days is linked to the increasing complexity of cases, often due to the age of the insurance products in question and additional time needed for parties to provide submissions

Resolution and timeframes

Complaint closure rates show a modest decline

AFCA closed 1,411 life insurance complaints in 2023-24, marking a 4% decrease from the previous year.

Improvements in resolution times

Notable progress was made in resolution times, with 14% of complaints resolved within 0-30 days, reflecting a 4% improvement. Additionally, 28% of complaints were settled within 31-60 days, and 34% were resolved in 61-180 days.

Extended resolution times increase

Complaints taking over 365 days to resolve increased from 54 to 74. The rise in complaints taking over 365 days is linked to the increasing complexity of cases, often due to the age of the insurance products in question and additional time needed for parties to provide submissions.

Industry trends and challenges

Small but significant

Although life insurance complaints are a smaller segment of AFCA’s overall caseload, they are significant due to the complexities often involved. Disputes frequently arise over claim denials, policy exclusions and delays in processing claims. Consumers often struggle with understanding policy terms, leading to misunderstandings and complaints when claims are made.

Challenges in claim processing and policy terms

Complaints about claim denials often stem from individuals facing significant life events or medical issues, adding stress to an already challenging situation. Rising life insurance costs and cost-of-living pressures are contributing to an increase in disputes, especially regarding policy cancellations due to non-payment of premiums.

Sector under scrutiny for transparency and communication

The Australian life insurance sector faces heightened scrutiny over transparency and claims handling. Consumers have expressed frustration with perceived communication gaps and lack of clarity, particularly during times of illness or financial hardship. Effective resolution of these complaints is crucial.

Document retention remains a critical issue

Ongoing complaints highlight the importance of insurers maintaining comprehensive records, including applications, underwriting files, disclosure documents and policies. Issues with document retention have led to disputes and should be managed effectively.

Case study – Navigating policy discrepancies

Background

The complainant held an income protection policy that included lifetime benefits. However, the insurer stated that if a disability developed after age 55, the benefit percentage would be reduced, and if the disability occurred after age 64, the benefits would cease entirely.

Complaint

The complainant stated that they were unaware of the policy conditions, claiming that the insurer’s documentation did not clearly present them.

During AFCA’s investigation, the insurer was only able to provide a sample policy, which was not specific to the complainant’s case. This sample conflicted with the annual schedules and the Customer Information Brochure (CIB). The CIB indicated that a full lifetime benefit was payable if a disability occurred before age 56, while the policy stipulated that benefits would reduce after age 55.

Furthermore, the CIB suggested a reduced lifetime benefit would apply if disability started before age 65, whereas the policy stated that no benefits would be provided for disabilities that began after age 64. The annual schedules further complicated matters by indicating a lifetime benefit for both sickness and injury, even beyond age 65.

Outcome

After a thorough review, the panel ruled that the insurer should provide the complainant with the full benefit amount until the policy’s expiry date, rather than limiting the payments to the age of 65 as initially indicated by some of the policy documents.

This decision considered the various conflicting documents provided by the insurer and that the insurer had only been able to provide a sample policy as evidence. 

The panel’s ruling aimed to ensure that the complainant received fair treatment and benefits in line with the intended coverage of the policy.

Case study – Acceptable levels of inconvenience associated with insurance claims

Background

The complainant held two insurance policies with the financial firm (insurer) for their spouse. Following the spouse’s death, the complainant filed claims under both policies. The insurer paid out the benefits along with interest, but the complainant sought compensation for non-financial loss, citing distress and inconvenience during the claims process.

Complaint

The complainant argued that they were entitled to compensation for non-financial loss due to the stress experienced throughout the claims process. Despite receiving the policy benefits and interest payments, the complainant felt that the delays and frustration justified an award for non-financial loss.

Outcome

AFCA reviewed the case and determined that the complainant was not entitled to compensation for non-financial loss. Although the complainant experienced some frustration, AFCA found that the delays in processing the claims were not unreasonable. The insurer had provided advance benefits promptly and had obtained the necessary medical evidence to process the claims.

AFCA’s decision was guided by our approach to non-financial loss compensation, which takes into account the typical stress and inconvenience associated with insurance claims. The insurer had already paid interest for the delayed payments and was not required to take further action.

In summary, AFCA ruled in favour of the insurer, concluding that there were no grounds for additional compensation beyond what had already been provided.

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